Bakambia v. Hart

Background

Marc Amouri Bakambia, who is incarcerated at the Minnesota Correctional Facility–Lino Lakes, sued Minnesota Department of Corrections employees Alexandria Hart, Christine Oberembt, and Corrections Officer Michael Oliveras. The opinion states that Bakambia alleges Hart and Oberembt were deliberately indifferent to his medical needs by delaying a medical appointment, and that Oliveras denied him access to prescription migraine medication and hid that medication.

Bakambia moved to compel additional responses to document requests and interrogatories that he served on September 15, 2025. He also asked the court to assess the credibility of the defendants, their lawyer, and officials involved in preparing the discovery responses. The defendants had responded initially and later supplemented their responses.

Legal standard

The court applied Federal Rule of Civil Procedure 26, which permits discovery of nonprivileged information relevant to a claim or defense and proportional to the needs of the case. A party seeking additional discovery must first show that the information is relevant. If the requesting party disputes a representation that all discoverable materials have been produced, the party must provide specific evidence suggesting that additional responsive materials exist; speculation is not enough.

Rulings on document requests

The court denied the motion as to Request for Production 1 because the defendants produced the property report they found, Bakambia obtained an identical report through the DOC’s internal records process, and he offered no evidence that another copy existed.

The court denied the motion as to Requests for Production 3 and 4. For Request 3, Bakambia’s allegations about discovery conduct in an unrelated case did not show that the defendants failed to search for records concerning Sergeant Mbaya Nyembwe’s efforts to find the medication. For Request 4, records from another correctional facility did not establish that the Stillwater facility maintained the same type of records.

For Request for Production 5, the court granted the motion and directed the defendants to request responsive documents from Centurion of Minnesota, LLC. The court found that the DOC’s contract gave the DOC a legal right to obtain relevant Centurion documents, placing those documents within the DOC’s control for discovery purposes.

The court denied the motion as to Request for Production 6 because the contract’s definition of subcontractor excluded the type of medical provider that the Noran Neurological Clinic falls within, so the court found no legal basis to require the defendants to request documents from that clinic.

The court granted the motion as to Request for Production 7. The documents produced did not clearly show that Dr. Shicker approved Dr. Todd’s recommendation. The defendants must produce responsive documents or clearly state that they could not locate any after a diligent search.

The court denied the motion as to Requests for Production 8, 9, 10, and 13. The court found Bakambia’s assertions about missing medical notes or other records speculative or conclusory, and the defendants had stated that they could not locate responsive documents for several requests without specific evidence showing that those documents existed.

For Request for Production 11, the court granted the motion only insofar as the defendants must ask Centurion whether it has responsive documents and produce any resulting documents. The court denied the request insofar as Bakambia sought additional documents that the defendants had already searched for and could not find. The court denied Request for Production 12 because it found no legal basis to require the defendants to request documents from the Noran Neurological Clinic.

For Request for Production 14, the court granted the motion insofar as the defendants must request responsive documents from Centurion and produce any resulting documents. It denied the motion insofar as Bakambia sought documents from the Noran Neurological Clinic.

The court granted the motion as to Request for Production 15. Bakambia provided specific evidence supporting an inference that additional scheduling records likely existed, including a statement that a neurology follow-up appointment had been scheduled. The defendants must search diligently for the requested records, including records related to that statement, and produce them or inform Bakambia that no responsive documents were found. The order also requires the defendants to request responsive documents from Centurion.

Rulings on interrogatories

The court denied the motion as to Interrogatory 1 because Bakambia offered no evidence that the defendants failed to ask the relevant officials for information, and the defendants represented that they had made a diligent inquiry.

The court granted the motion as to Interrogatory 3 and required an unambiguous answer about whether Officer Oliveras’s duties included inventorying and returning prisoners’ property before and after segregation transfers.

The court granted the motion as to Interrogatory 7 and required a specific answer about whether Officer Oliveras returned inventoried property to all inmates released from segregation between 7 A.M. and 2 P.M. on June 11, 2024. If the defendants lacked an adequate basis to answer, they could say so.

The court denied the motion as to Interrogatory 8 because it could not compel Officer Oliveras to provide details he said he could not remember. The court granted the motion as to Interrogatory 10 and required the defendants to address whether Sergeant Nyembwe went to the laundry area to retrieve Bakambia’s medication, whether Nyembwe found it, and whether Oliveras had moved it if Nyembwe did not find it. The defendants could state that they could not confirm or deny some or all of the information.

The court denied the motion as to Interrogatory 12 because the defendants had already provided Bakambia with a copy of the interrogatories and had responded to the substance of the intended interrogatory. The court also denied Interrogatories 15 and 18. It found the response to Interrogatory 15 responsive to the request as written, and it found that Interrogatory 18 was not an appropriate way to request production of documents.

Credibility assessment and disposition

The court denied Bakambia’s request to assess the credibility or truthfulness of the defendants’ discovery responses and to require alternative responses. The court explained that a motion to compel is used to obtain answers or documents, not to resolve factual disputes about whether discovery responses are truthful. The court also denied Bakambia’s request for sanctions because he offered only conclusory allegations and no evidence that anyone involved in the litigation had lied to him or the court.

The final order states that Bakambia’s Motion to Compel Discovery Disclosures and Motion for Credibility Assessment was GRANTED IN PART and DENIED IN PART. The defendants must request documents from Centurion responsive to Requests for Production 5, 11, 14, and 15; conduct diligent searches for documents responsive to Requests 7 and 15; and provide the specified answers to Interrogatories 3, 7, and 10. The motion was denied in all other respects.